Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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Legality of SFIO Investigation - non-maintenance of the registered office at the address mentioned in Form No.10 - The High court found no statutory or legal impediment to assigning the investigation to the SFIO under Section 212, even if investigations under Section 210 were already underway. The statutory framework does not prohibit such action, and it serves the purpose of a thorough and multidisciplinary investigation. - The court determined that at the investigation stage, the application of the principles of natural justice is not mandatory. The non-service of the order to the petitioner does not vitiate the proceedings.
Legality of SFIO Investigation - non-maintenance of the registered office at the address mentioned in Form No.10 - The High court found no statutory or legal impediment to assigning the investigation to the SFIO under Section 212, even if investigations under Section 210 were already underway. The statutory framework does not prohibit such action, and it serves the purpose of a thorough and multidisciplinary investigation. - The court determined that at the investigation stage, the application of the principles of natural justice is not mandatory. The non-service of the order to the petitioner does not vitiate the proceedings.
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